2023 ACA 6055/6056 reporting and new guidance

UnitedHealthcare will post 1095-B forms on member portals (e.g., myuhc.com®) for fully insured subscribers prior to the Jan. 31, 2023, filing deadline. Based on 2022 IRS guidance, the ability to post and not mail is now permanent. Resident subscribers in states with the Individual Mandate will have forms mailed unless the member has requested paperless communications.

Forms that are submitted to the Internal Revenue Service (IRS) or forms for Individual Mandate states (California, Washington, D.C., New Jersey) must be submitted by March 31, 2023. The Rhode Island Tax Revenue Department requires the submission by Jan. 1, 2023.

Key information on UnitedHealthcare and 1095-B forms

  • The 1095-B forms are posted for members and are not mailed to employers. The 1095-C form indicates if the employer offered MEC
  • If the member requests a printed version of the 1095-B, the member may call the customer service phone number on the back of their ID card
  • Employers may not request 1095-B forms for their employees or receive a report of employees who receive a form
  • The 1095-B form indicates the employer offer of minimum essential coverage (MEC) and the months the employee was covered
  • Forms that UnitedHealthcare sends to IRS (and state tax revenue where needed) include:
    • 1094-B Transmittal of Health Coverage
    • 1095-B Health Coverage

Key information on Employer requirements for 1095-C forms

  • Applicable Large Employers (ALE) and ASOs must submit 1095-C form
    • The 1095-C form indicates if the employer offered MEC, if the plan(s) offered was minimum value and affordable, and any months the employee was covered
    • Both fully insured and ASO 50+ groups are required to furnish the 1095-C to subscribers by Jan. 31, 2023, and submit it to the IRS by March 31, 2022
  • Forms that employers send to IRS (and to state tax revenue departments when required) include:
    • 1094-C Transmittal of Employer-Provided Health Insurance Offer and Coverage
    • 1095-C Employer-Provided Health Insurance Offer and Coverage

State reporting requirements

Although for a couple of years individuals are no longer subject to a federal IRS penalty if they do not comply with the federal individual mandate coverage requirement under the ACA, a few states implemented their own individual mandate requirement.

  • Washington, D.C., California, New Jersey, Rhode Island and Vermont have initiated their own Individual Mandate requirement for residents
  • These states have both federal and state tax requirements. UnitedHealthcare submits the FI 1095-B forms to the state tax revenue department and the ALE and ASO must submit the 1095-C to the tax revenue department by the required date
  • For RI groups the form must be submitted to the RI revenue department by Jan. 31, 2023, rather than March 31, 2023

 

UnitedHealthcare’s approach

  • For fully insured groups, UnitedHealthcare will send the 1095 form to subscribers and to the IRS
  • Fully insured ALEs are also required to send the IRS 1095-C forms
  • For All Savers/Level Funded, UnitedHealthcare prepares the 1995-B forms, which the employer then provides to their subscribers and to the IRS
  • For large ASO groups, the customer prepares the 1095-C form, which they furnish to subscribers and to the IRS
  • ASO groups may request a custom eligibility report to include month-by-month coverage that is available for a fee.

Reminder: Elimination of transitional good faith relief

The IRS eliminated the ability to provide transitional good faith relief for furnishing statements to individuals under Sections 6055 and 6056. Such relief covered incorrect or incomplete information, including tax identification numbers (TINs) or dates of birth, reported on information returns or statements, but it did not cover failure to file timely. Accordingly, the IRS discontinued transitional good faith relief with respect to furnishing statements after tax year 2020.

For questions, please contact your broker or UnitedHealthcare representative.

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